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Great News for MIACCA Members!
According to this MPSC Order issued on January 23, 2020 in Case U-18361, MIACCA's comments regarding VAPS information sharing were basically adopted by the Commission. This means that contactors can now request the same customer lists that the utilities share with their VAPS programs, such as Appliance Service Plans programs, without having to sign a utility generated non-disclosure agreement (NDA). Contractors can now start using the utility current customer list to do target marketing in their areas. To find out who to contact at the utility to request the customer list contractors can go to the MPSC website
This is, yet, another great benefit of being a MIACCA Member!
Last month, Director of the Department of Environment, Great Lakes and Energy (EGLE) Liesl Eichler Clark announced Robert Jackson as the new Energy Ombudsman.
Jackson is the Manager of the Energy Office where he oversees the State Energy Program, and is directly responsible for the Energy Efficiency and Renewable Energy Revolving Loan Program, industrial E2 Program, and Techology Demonstration Program.
Read the official letter here
On December 20, 2019 MIACCA submitted these rule change proposals to the Skilled Trades Regulatory Act. MIACCA will stay involved and keep you posted of any updates as we receive them.
MIACCA is Michigan's best resource for CSD-1 training. Our instructor, Phil Forner, is incredibly knowledgeable and engaging. We provide those who successfully complete our one day course with a CSD-1 certification. Our CSD-1 training is also one of a few that is also NATE Certified.
If you need CSD-1 training for your organization, please contact us so that we may get you on our 2020 schedule.
When MIACCA met with MPSC Staff, they asked MIACCA to advise them of any concerns we might have regarding the 2018 VAPS reports. If any MIACCA members have concerns with the 2018 VAPS Annual Reports complying with the Code of Conduct please submit those concerns to MIACCA by December 23.
You may review the most up to date Code of Conduct reports and forms at https://miacca.org/Code-of-Conduct
The Skilled Trades Regulation rule set is now open, and LARA is seeking input for the following rule sets: Board of Boiler Rules/Code, Board of Mechanical Rules, Building Officials, Plan Reviewers and Inspectors Rules, Electrical Administrative Board General Rules, and State Plumbing Board License Rules. For your convenience, attached is the Proposed Rule/Code Change Request form. The current rule sets affected can be reviewed at Administrative Rules webpage. Proposals for this rule set must be submitted to LARA-BCC-Rules@michigan.gov by 5:00pm on Friday, December 20, 2019. Updates to the rule set's status will be posted on our website.
If you wish to submit your comments through MIACCA, please email them to email@example.com by Friday, December 13, 2019.
The Michigan Air Conditioning Contractors Association (MIACCA) on behalf its mechanical contractor members, whom for decades have competed against utility appliance service plans (ASP), submits the following comments as requested by the Michigan Public Service Commission (Commission) in its September 26, 2019 Order in Case No. U-18361. Specifically the Commission requested comments on 4 issues, stated below along with the MIACCA comment:
1) Data Security/Privacy: Utilities are required to comply with all data privacy tariffs. Rule 9(1). A customer list may only include the name and address of a customer. Rule 9(2). Does a customer list require the heightened security discussed by the utilities? Customer consumption and billing information requires prior written customer approval in order to be shared. Rule 9(4). In light of the prior written approval requirement, does this information require the heightened security discussed by the utilities? Are there instances where a utility should routinely require an affiliate or VAPS to acquire the requested information from a third party? Alternatively, should the Commission consider amending the rules to allow no information sharing beyond the requirement of MCL 460.10ee(10)(a) for the sharing of customer lists?
MIACCA Comment: Given that with MCL 460.10ee(10)(a) the Legislature specifically provided for the utilities to make available the customer list without any regards to data privacy tariffs the Commission should not impose or allow the utility to impose any further restriction to obtaining the customer list on a provider of a similar program or service. The customer mailing list is not information that warrants additional data privacy tariff concerns. Utility customer consumption, billing and other information is not specifically authorized by MCL 460.10ee to be shared by the utility with its affiliate or VAPS provider as that is preferential treatment and unauthorized information sharing beyond MCL 460.10ee; therefore such sharing of information other than customer mailing list must be prohibited by the Commission from being shared by the utility with its affiliate or VAPS provider in order to uphold the letter and intent of MCL 460.10ee(1) and (6)(c). The Commission must amend its rules to prohibit information sharing beyond the requirement of MCL 460.10ee(10)(a) for the sharing of customer mailing lists. If an utility does not want to expose itself to potential data privacy issues from providing the customer list pursuant to MCL 460.10ee(10)(a) then the utility should choose not to offer the voluntary VAPS. Because of the potential for utility information sharing abuse or claimed oversight by the utility for its affiliates or VAPS provider’s benefit, all sharing requests for the list of customers from any affiliate, VAPS provider or competitor must go through the MPSC website. This would help ensure that only the customer list is being provided by the utility along with being timely provided to competitors as required.
2) Timing of Response: MCL 460.10ee(10)(a) allows 5 business days for the provision of customer lists. Should this standard be adopted for all information sharing responses? This would become the meaning of "contemporaneously" under Rule 9(3), (5), and (6).
MIACCA Comment: Yes, 5 business days should be adopted by the Commission for the meaning of “contemporaneously”.
3) Same Terms and Conditions: Rule 9(3), (5), and (6) require the "same form and manner" for information sharing. Does this mean provision of the identical information?
MIACCA Comment: Yes the utility must provide the information in a nondiscriminatory basis, MCL 460.10ee(10)(a), to the extent that the information provided by the utility is in a standard free market format that a competitor can readily use and not in an utility format that requires expensive and or specialized software to access. The Code of Conduct must include measures to prevent preferential treatment by the utility to its affiliate and or VAPS provider, MCL 460.10ee(1).
4) Competitor versus Non-Competitor: How should the requesting party establish that it is a current or potential/new competitor of the party that received the shared information?
MIACCA Comment: The Commission should require the requester to self-certify that they are representative of a provider of a similar program or service or potential provider. Utilities have the option of giving notice or its intent to offer VAPS and thereby exploring the feasibility of such; potential competitors should also be given the opportunity to obtain the information and do its own feasibility analysis. Furthermore the burden of proof must remain with the utility if the utility wants to challenge this certification as it the utility that is subject to penalties and costs for violations, MCL 460.10ee(14).
On October 22, 2019 MIACCA sat down with Mike Byrn, COO of the Michigan Public Service Commission (MPSC) and his staff to follow up with his presentation at our Annual Meeting regarding the VAPS program. We discussed what future MPSC staff goals are to handle the annual VAPS and the review process. They had learned a lot going through this first process and appreciated our input on how to streamline things in the future. They will be putting procedures in place to discuss with the commission about implementing. Although there is nothing that says a company cannot file their annual reports confidential, those filed confidential are going to raise a red flag with staff and prompt scrutiny moving forward.
We discussed the change in the postage allocation going from 10.4 cents per envelope to having no allocation method with the new code of conduct change. As the MPSC works through the discovery process, they will determine if an allocation method is needed and are open to suggestions on said methods.
We brought up our concerns about database sharing. For example, utilities have the ability to know what type of wattage is used and what age a home is, thus gaining an unfair advantage to contractors and marketing. We are hoping that any such database would be provided to the public and not deemed private.
The MPSC was very open into answering our questions and are taking steps to integrate our suggestions to propose to the commission for approval. We look forward to a continued working relationship with the MPSC.
November 2, 2019- Grand Rapids
Please provide this flyer to your techs!
PROVIDING HEATING ASSISTANCE TO THOSE IN NEED
15 Point Furnace Check
With Old Man Winter on his way, it is time to think about all of those who may not have the means for a furnace inspection, and worse yet, do not have the means to afford the repairs. Many may be destined with a forecast of cold weather outside and inside their own homes.
The good news is we can help!
This event is to provide goodwill to those in need in our communities & to promote quality contractors and their employees. Also, this event gives contractors the opportunity to have HVACR students accompany them to gain your knowledge and expertise as they prepare for their careers in our industry. They also get to participate in the spirit of giving back.
If your organization is interested in participating in Grand Rapids, or has a low income project they would like to provide service to, themselves, anywhere in the state, please contact Executive Director M.J. D'Smith at 517-285-2420 or firstname.lastname@example.org We are also looking for additional homes in Grand Rapids, if you might know of any.
The event will start at 8:30 a.m. at Schaafsma Heating and Cooling with coffee and doughnuts. We understand that you and your techs will be sacrificing a couple of hours on a Saturday, but you will be making a difference for those in need all through the heating season! For your generous participation in this event, MIACCA will hold an Appreciation Dinner the following week or so honoring those who participate. Your organization will also be recognized on our website and email blasts.
Make a Difference!! We look forward to hearing from you soon!
A BIG "Thank You" to our member JOHNSTONE SUPPLY MUSKEGON GROUP for sponsoring this event by graciously supplying parts.
MPSC working to make access to utility customer information shared with VAPS easier for
competitors to obtain.
On September 26, 2019 the Michigan Public Service Commission (MPSC) approved the following order for the development of a MPSC website for information sharing in regards to the utility customer information currently being shared with their Value Added Products and Services (VAPS) as required by MCL 460.10ee(10)(a).
MIACCA has met with the MPSC and has been advocating for appropriate procedures for contractors to have access to the same utility customer information currently being shared with VAPS, for their appliance service programs (ASP).
Mike Byrne, COO, of the MPSC gave a presentation (view presentation here) at the MIACCA September 19th meeting and many questions from our members expressing the need for such an avenue to be put into place as soon as possible. As a result, MIACCA is proud to let you know that we played an important part in getting this website put into place and will continue to represent the contractor's interest.
MIACCA will be sending the link to our members as soon as it is made available. In the meantime, the MPSC also temporarily approved the:
This form is to be used until the website is up and running.